Who Needs To Certify SWPPP Plan? What Certifications Are Needed?

Under State and EPA stormwater permitting rules, a Stormwater Pollution Prevention Plan (SWPPP) may need to be certified. This signed SWPPP Certification is in addition to other types of certifications that may be required. The types of certifications will vary depending on the State and type of permit; in addition to SWPPP Certification, some other types of certifications might include:

• Non-stormwater Discharge Certification,
• No-exposure Monitoring Exemption Certification;
• Heavy Metal No-exposure Certification (in Texas);
• Annual Site Compliance Certifications;
• Endangered Species Certifications;
• Historic Places Certification,
• Environmental Professional Certification (in Indiana)
• Certified Stormwater Operator Certification (in Michigan)
• Others.

Rail Car Loading Area Covered In SWPPP Inspection

SWPPP Certification – What is Being Certified?

In most cases, the SWPPP Certification statement indicates that the SWPPP has been 1) prepared; 2) implemented and that 3) the SWPPP conforms to the requirements of the discharge permit. The SWPPP Certification generally includes a statement that the information documented is correct. The exact wording and scope of the certification statement will vary from State-to-State, but here is an example: "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."

 
Non-Stormwater Discharge At Industrial Facility

Who needs to certify the SWPPP?

In some States (for example, Michigan, Indiana, Connecticut and others), the SWPPP needs to be signed by a certified or qualified environmental professional. In most States, the SWPPP also needs to be signed by a Responsible Company Officer, or his/her duly authorized representative. State or EPA rules will determine who can sign the SWPPP. This SWPPP Certification can be in addition to any certifications needed by a qualified environmental professional.

 For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

 

Caltha LLP | Your Stormwater Permit, SWPPP 

and Spill Plan Partner

Construction SWPPP And Contractor SWPPP Training, Spill Training

Caltha LLP Project Summary

Project: Construction Stormwater Permitting, SWPPP & Contractor Training 
Client: National Home Builder
Location(s): Minnesota

Key Elements: Stormwater permitting, SWPPP, Inspection training, Spill Control Plan

Overview: Caltha LLP was retained by a national home builder/developer to provide technical services required for a 8-ac single family home development. Caltha staff prepared the project stormwater pollution prevention plan (SWPPP), erosion control plan, spill control plan and then completed the permit application materials. Once permitted, Caltha staff provided SWPPP training to all site inspectors and subcontractors.


 
SWPPP and SWPPP Training For Residential Site Construction

For more information on Caltha LLP construction stormwater services, go to the Caltha Storm water Permitting and Compliance Page

   

Caltha LLP | Your Stormwater Permit, SWPPP 

and Spill Plan Partner

Do Electric Transformers Need To Be In SWPPP and SPCC Plan?

Electric transformers are found at almost every larger commercial, institutional and industrial facility. Sometimes this equipment is owned by the facility owner and sometimes by the power company. For some facilities, it is not always clearly understood who owns and is responsible for transformers.

Can Electric Transformers Leak Oil?

Yes, electric transformers can leak oil, but only if they actually contain oil.

How Can I Tell If Electric Transformer Contains Oil?

For newer transformers, the quantity of oil in the unit is usually found on the label. For older equipment, this information may not be on the label, or the label may have been removed or is illegible. In this case, a visual inspection of the equipment by a knowledgeable person can usually determine if it contains oil or not.     Not sure?   Send Caltha a photo and we may be able to determine this - send to info@calthacompany.com

Who Is Responsible To Clean Up Leaks From Transformers?

This will depend on State laws. In general, the Owner of the equipment is responsible. However, for a property owner whose property has been impacted by a leaking transformer, the issue could affect the value of the property and they may voluntarily elect to clean up leaks.

What Are The Environmental Risks For Electric Transformers?

A risk for oil spills exists for any oil-filled transformer. Older transformers commonly contained PCB oils. Use of PCB oils has been phased out and newer equipment is often labeled "No PBC"; however older electric transformers could still contain PCBs which makes clean up more involved.

Leaks can occur over long periods and accumulate slowly. The other risk is an emergency spill caused by a fire or the transformer being damaged by vehicles, etc. These risks are minimized by ensuring equipment is included in pollution prevention plans and spill plans (such as SWPPP, SPCC Plan or other spill plans) and is regularly inspected and maintained.

Typical Leaking Electric Transformer

SWPPP Plan, SPCC Plan, RCRA Plan In Pensacola, Tallahassee Area

Caltha LLP provides expert stormwater compliance services to clients on northwest Florida and south Alabama, including areas surrounding:

• Pensacola, Florida
• Tallahassee, Florida
• Mobile Alabama

Caltha prepares stormwater pollution prevention plans (SWPPP), spill prevention plans, SPCC plans, RCRA contingency plan an other related plans. Caltha also provides a full range of environmental and safety training services.
To request a quote for a SWPPP, SPCC or other plan, click here and complete the EH&S Plan Quote Request Form.

IA Stormwater Permit And Compliance Consultant- SWPPP Engineer

Caltha LLP maintains a library of SWPPP Templates developed to meet the requirements of individual States, including Iowa. Separate stormwater plan templates are provided to Industrial, Municipal (MS4) and Construction stormwater dischargers. Our Iowa SWPPP templates are updated to meet new State permit requirements as new or revised permits are finalized.

Leaking Fuel Lines From Underground Fuel Tank

To reduce the level of effort required for facilities to come into compliance with new permit requirements, Caltha LLP has prepared a SWPPP template based on Iowa Department of Natural Resources (IDNR) permit requirements, including site specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a State Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the stormwater general permit.


Click here to request further information or a quote to prepare a facility SWPPP or revise your existing SWPPP. Click here to review example Caltha projects in Iowa and IA regulatory updates.

SWPPP and Permit Compliance Training For Revised WDNR Tier 2 Permit

Caltha LLP Project Summary

Project: SWPPP and Permit Compliance Documentation To Meet Tier 2 Permit
Client: Concrete manufacturer
Location(s): Wisconsin

Key Elements: Facility SWPPP, stormwater inspection, visual stormwater monitoring

Overview: Caltha LLP was retained by this regional concrete manufacturer to conduct compliance reviews and prepare updated SWPPPs for two of its facilities located in Wisconsin. Both sites were covered under the WDNR Tier 2 General Permit for discharge of industrial stormwater. Caltha staff conducted a site visit and met with plant personnel to determine what updates were required to the existing facility SWPPP to meet the newly revised WDNR permit. A revised SWPPP was issued to each location which included updates to quarterly monitoring procedures, spill prevention measures, routine employee training and monthly housekeeping inspections.


For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Compliance With State Multi-sector Industrial General Permit | Seminar Module

The link below provides training slides from a training module on basic compliance strategies to address general permit requirements. The emphasis of the training module is to provide photograph examples of key areas which should be concerned in developing a site-specific SWPPP.

Presentation Slides: Complying with State Industrial Storm Water Requirements

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Revised Wisconsin DNR Tier 2 Industrial Permit

The Wisconsin Department of Natural Resources (WDNR) has release the revised Tier 2 permit under Chapter NR 216, Subchapter II — Industrial Storm Water Discharge Permits.  The revised permit became effective on June 1, 2016 and expires on May 31, 2021.




Caltha LLP has been providing technical services to facilities located in Wisconsin to bring them into compliance with the revised permit. Click here to review an example project to prepare a revised SWPPP and permit compliance documentation to meet Tier 2 permit


Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training. For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Industrial Stormwater SWPP and MPCA Permit Compliance Program Development For Transportation Facility

Caltha LLP Project Summary

Project: SWPPP and MPCA Permit Compliance Program For Transportation Facility
Client: Transportation Company
Location(s): Minnesota

Key Elements: MPCA industrial stormwater discharge permit compliance, SWPPP, Facility inspections, Storm water BMP

Overview: The national transportation company selected Caltha to conduct a facility assessment to determine if the operations could meet "No Exposure" requirements under the MPCA general industrial permit. Caltha prepared a list of corrective actions which would be required to comply with MPCA requirements and discussed potential costs with facility managers. Upon consideration of costs, facility management determined that applying for coverage under the Minnesota industrial permit was the preferred alternative. Caltha then prepared the storm water pollution prevention plan (SWPPP) using Caltha's SWPPP template designed to meet permit requirements. Caltha also prepared a permit compliance plan and site-specific inspection checklists to streamline on-going permit compliance tasks that the facility staff would be conducting.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training. For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Response To Notice Of Violation For Industrial Stormwater Discharges and Non-Storm Water Discharge

Caltha LLP Project Summary

Project: Response To MPCA NOV For Industrial Stormwater Discharges and Non-Storm Water Discharge
Client: Transportation Sector
Location(s): Minnesota

Key Elements: Compliance with No Exposure Certification, Compliance with prohibition of unauthorized non storm water discharge

Overview: In a routine compliance inspection of industrial sites which had submitted no exposure certifications (NEC) being conducted by the State, this facility was found to be in non-compliance with both the conditions of the NEC and was also found to be discharging wash water without a permit. The facility was placed in enforcement action to resolve these issues. Caltha LLP was retained by the facility to assist them in evaluating requirements to meet the NEC and to identify options for addressing unpermitted discharge. Working with facility management, it was determined that costs for necessary corrective actions to comply with the NEC were too high compared to costs to obtain and comply with an industrial stormwater discharge permit. The facility terminated its NEC and applied for permit coverage. Caltha assisted the facility in preparing a facility SWPPP using our Minnesota SWPPP template and a permit compliance plan. Alternate off-site facilities were found to eliminate the discharge of unauthorized wastewater releases from the facility.

For more information on Caltha LLP services, go to the Caltha Contact Page

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Reissued Kentucky General Industrial Permit For "Other Facilities"

Note: Click here to read update on release of Final Kentucky General Stormwater Permit and NOI submittal dates.

On September 13, 2012, the Kentucky Energy and Environment Cabinet, Department of Environmental Protection, Division of Water (DOW) released a draft Kentucky Pollutant Discharge Elimination System (KPDES) General Permit for Stormwater Discharges Associated with Industrial Activity from “Other Facilities”. The previous KYR000000 permit had expired in 2007 and was administratively continued. This draft General KPDES Permit does not address specific categories of facilities, but provides permit coverage for facilities that are not required to obtain an individual KPDES Permit.

Currently, industrial stormwater dischargers in Kentucky are required to apply for an individual KPDES permit, which does not change under the new draft permit. Facilities that are subject to a promulgated national effluent guideline and those facilities that discharge to a receiving water that is subject to a TMDL for suspended solids are not eligible for coverage under the general permit. Some of the key changes from the previous permit include:

1. Specific effluent limits for Total Suspended Solids (TSS), Oil and Grease (O&G), and pH are in place of the previous requirement to monitor and report the results of monitoring for these parameters. Monitoring is no longer required for Chemical Oxygen Demand (COD).
2. The Stormwater Best Management Practices (SWBMP) Plan will now be refered to as a “Stormwater Pollution Prevention Plan (SWPPP).”
3. Inspections with subsequent written reports to document the findings of the inspections would be required on a minimum weekly basis and in response to 2-year, 24-hour storm events that occur.
4. The SWPPP Site Map must include additional features to be shown including directions of stormwater flow, locations of impaired waters and any TMD’s associated with them, and locations of stormwater monitoring points.
5. The SWPPP must include procedures for preventing and responding to spills, and schedules for inspections, preventive maintenance, and employee training required.
6. The SWPPP must contain a daily precipitation log, incident reports in response to spills, employee training records, and control measure maintenance and repair logs.

Caltha LLP maintains a library of SWPPP templates to meet general permit requirements for individual States, including Kentucky. Once the revised permit is issued, Caltha will revise the Kentucky SWPPP template to meet any new requirements and will use this to support our clients located in Kentucky. Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting and Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.
For further information contact Caltha LLP at info@calthacompany.com  

 

Storm Water Plan Certification - What is Certified? Who Must Sign?

Under State and EPA stormwater permitting rules, a Stormwater Pollution Prevention Plan (SWPPP) may need to be certified. This signed SWPPP Certification is in addition to other types of certifications that may be required. The types of certifications will vary depending on the State and type of permit; in addition to SWPPP Certification, some other types of certifications might include:

• Non-stormwater Discharge Certification,
• No-exposure Monitoring Exemption Certification;
• Heavy Metal No-exposure Certification (in Texas);
• Site Compliance Certifications;
• Endangered Species Certifications;
• Historic Places Certification
• Others.

SWPPP Certification – What is Being Certified?
In most cases, the SWPPP Certification statement indicates that the SWPPP has been 1) prepared; 2) implemented and that 3) the SWPPP conforms to the requirements of the discharge permit. The SWPPP Certification generally includes a statement that the information documented is correct. The exact wording and scope of the certification statement will vary from State-to-State, but here is an example:

"I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."


Who needs to certify the SWPPP?
In some States (for example, Michigan, Indiana, Connecticut and others), the SWPPP needs to be signed by a certified or qualified environmental professional.

In most States, the SWPPP also needs to be signed by a Responsible Company Officer, or his/her duly authorized representative. State or EPA rules will determine who can sign the SWPPP. This SWPPP Certification can be in addition to any certifications needed by a qualified environmental professional.

Click here for more information on State-specific SWPPP Templates.


Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting and Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Louisiana SWPPP Template and Storm Water General Permit Compliance Plan

The Louisiana Department of Environmental Quality (DEQ) has finalized a revised General Permit for Storm Water Discharges Associated with Industrial Activity (Multi-Sector General Permit, or MSGP). This permit replaced the previous Louisiana general permit, which had expired. The Louisiana general permit is modeled after the US EPA MSGP and defines sector specific requirements for each of 29 different industrial sectors. For most facilities subject to the existing general permit, the revised MSGP will require a significant revision to the facility stormwater pollution prevention plan, or SWPPP.

To reduce the level of effort required for facilities to come into compliance with new permit requirements, Caltha LLP has prepared a SWPPP template based on Louisiana permit requirements, including Louisiana specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a Louisiana Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the LDEQ general permit.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Caltha LLP provides expert consulting services to public and private sector clients in Louisiana and nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Ohio SWPPP Template, Inspection Checklists and Compliance Plan

The Ohio Environmental Protection Agency (OEPA) has proposed a revised General Permit for Storm Water Discharges Associated with Industrial Activity (Multi-Sector General Permit, or MSGP. This permit will replace the existing Ohio general permit, which expires on May 31, 2011. The draft Ohio general permit is modeled after the US EPA MSGP and defines sector specific requirements for each of 29 different industrial sectors. For most facilities subject to the existing general permit, the revised MSGP will require a significant revision to the facility stormwater pollution prevention plan, or SWPPP.


[read a Regualtory Briefing on the revised Ohio MSGP]


To reduce the level of effort required for facilities to come into compliance with new permit requirements, Caltha LLP has prepared a SWPPP template based on Ohio permit requirements, including Ohio specific quarterly inspection checklist, quarterly visual assessment checklist, quarterly benchmark monitoring checklist, and an annual comprehensive site inspection checklist. Caltha has also prepared a Ohio Stormwater Permit Compliance Plan to assist permitted facilities in organizing and planning new compliance requirements under the OEPA general permit.


For further information on Caltha's Ohio SWPPP Templates (or other State SWPPP templates), email: info@calthacompany.com



Caltha LLP provides expert consulting services to public and private sector clients in Ohio and nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP) , Stormwater Monitoring and Stormwater Training.






For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Qualified SWPPP Developer & Qualified SWPPP Practitioner Requirements Under Draft California Permit

UPDATE: On July 16, 2012, an updated draft was released. Click here for a summary of the revised draft ICP

On January 28, 2011, the California State Water Resources Control Board released its draft General Permit for stormwater discharges associated with industrial activities. The draft NPDES permit proposes several changes from the existing California General Permit.

One of the important changes will be especially significant for facilities that have in the past prepared their own stormwater pollution prevention plan (SWPPP). Under the proposed permit, all dischargers will need to appoint a Qualified SWPPP Developer (QSD) to prepare, write, and make any revisions to the SWPPP, and appoint a Qualified SWPPP Practitioner (QSP) to help implement the SWPPP.

The minimum requirements to become a certified Qualified SWPPP Developer includes have one of the following registrations for certifications, and appropriate experience, as required for:

• California registered professional civil engineer;
• California registered professional geologist or engineering geologist;
• California registered landscape architect;
• Professional hydrologist registered through the American Institute of Hydrology;

In addition, the QSD must successfully complete the State Water Board-sponsored or approved QSD training course within one year after the effective date of this General Permit.

Unless a facility has a registered engineer, geologist, landscape artitict, or professional hydrologist on staff, facilities subject to the permit will need to contract outside professional services to prepare, certify and update the SWPPP.

The minimum requirement to become a certified Qualified SWPPP Practitioner is to successfully complete the State Water Board-sponsored or approved QSP training course within one year from the effective date of the General Permit.
Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Difference Between SPCC SWPPP SWP3 Plans

What is the Difference Between a SPCC Plan and a SWPPP Plan?
Some municipal and industrial sites may be required to prepare and implement either a SPCC Plan, a SWPPP Plan, or both. SPCC Plans and SWPPP Plans are different documents, requiring different types of information, and are required under different regulatory programs.


SPCC Plans. SPCC Plans are required under the federal Oil Pollution Control Act, and the requirements are specified in 40 CFR 112 ("SPCC Rule"). In order to determine if SPCC Rules apply to an individual site, an inventory of oil and fat containing vessels, which may include oil-filled equipment, must be made. The results are compared to the SPCC threshold. If the site exceeds the threshold, a SPCC Plan needs to be prepared and the site needs to comply with other aspects of the SPCC Rule.


SWPPP Plans. Stormwater Pollution Prevention Plans ("SWPPP Plans", or "SWP3 Plan") are required by the federal Clean Water Act, specifically under requirements for National Pollutant Discharge Elimination System (NPDES). The requirement to prepare and implement a SWPPP, and the contents of the SWPPP, will be defined in an NPDES permit. Many industrial, municipal and construction sites are required to obtain an NPDES permit to discharge stormwater, and are therefore required to have a SWPPP.

The SWPPP and SPCC Plan can be related; most SWPPPs need to incorporate procedures for spill prevention and response. Sites that are required to have a SPCC Plan can use that plan to satisfy this one requirement, as long as the oils and fats addressed in the SPCC Plan are the only materials that need to be addressed in the SWPPP.  In summary, sites could need either a SPCC Plan, a SWPPP, or both.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address preparation of SPCC Plans and 40 CFR 112 Compliance Programs, preparation of Stormwater Pollution Prevention Plans (SWPPP), and SPCC Training and SWPPP Training. For further information contact Caltha LLP at
info@calthacompany.com

MPCA SWPPP Permit Revision - Industrial Stormwater Requirements

On July 6, 2009, MPCA is scheduled to release its proposed Multisector General Permit (MSGP) for industrial stormwater discharges. This permit represents a major shift in stormwater pollution prevention (SWPPP) requirements for Minnesota industries and other affected sectors, such as transportation, POTWs, landfills, etc.

In July, Caltha LLP will be hosting seminars in several cities across Minnesota to provide information on the proposed permit and rule changes, and steps facilities can take to reduce their impact.

For more information, go to:

MPCA SWPPP Permit - Industrial Stormwater Permit Reissue Seminars

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

SWPPP - Does My Stormwater Pollution Prevention Plan Expire?

From time-to-time, Caltha receives inquiries from facilities that believe their Stormwater Pollution Prevention Plan (SWPPP) may have "expired".

The SWPPP, prepared in accordance with State or EPA permit requirements, is a "dynamic" document, and does not expire. However, at any point in time, the SWPPP needs to accurately reflect the current physical layout of the facility, the existing stormwater controls and spill containment and control measures, and the current emergency response procedures.

Because facilities change overtime, the SWPPP needs to be reviewed and updated accordingly. In many cases, the SWPPP needs to be amended prior to making the changes. The SWPPP may have to be revised for a number of different reasons, including:

• Changes to physical layout of the site


• Changes to locations for specific industrial activities


• Changes to materials handled at the site


• Changes to best management practices (BMPs) or stormwater controls


• Changes to Pollution Prevention Plan team members and/or responsibilities.

Facilities may also need to review and revise the SWPPP in response to issues that are identified during site inspections, site compliance evaluations, or benchmark stormwater monitoring results.

[Read more about relationship between benchmark monitoring and SWPPP]

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Draft MPCA SWPPP Requirements for Food Products Facilities

On July 6, 2009, the Minnesota Pollution Control Agency released its proposed multisector industrial stormwater discharge general permit. This permit, once promulgated, will replace the existing industrial stormwater permit, which expired in October of 2002.

[Read a summary of the overall Minnesota permit, stormwater monitoring, and sector requirements]

Caltha LLP will be conducted seminars on the proposed sector requirements in July & August 2009. Caltha MPCA Industrial Stormwater Permit Requirements Seminars

The proposed permit details requirements for 29 different industrial sectors. The requirements described below are proposed for the Food and Kindred Products Sector (Sector U). Sector U covers a fairly broad range of facility types, including meat products, dairy products, bakeries, beverage products, and many others. These requirements are in addition to permit requirements that apply to all sectors.

Employee Training:
SWPPP training programs must include information on:
1) used oil and spent solvent management;
2) segregation of organic materials, raw materials, and products from contact with stormwater and precipitation; and
3) pest control

[Read more about Minnesota stormwater training]

Inspections:
Inspections must include:
a) waste management units;
b) vents and stacks associated with industrial activities;
c) spoiled product and broken product container holding areas;
d) animal holding pens;
e) staging areas; and
f) air pollution control equipment.

At least two of the monthly inspections must be conducted during runoff events. One of the inspections must be performed during a snow melt runoff event.

Stormwater Pollution Prevention Plan (SWPPP) Content:
The SWPPP must identify:
1) vents and stacks from cooking, drying, and similar operations;
2) dry product vacuum transfer lines;
3) animal holding pens;
4) spoiled product; and broken product container storage areas.

Potential Pollutant Sources:
The SWPPP must describe application and storage of pest control chemicals (e.g., rodenticides, insecticides, fungicides) used on plant grounds.

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations or values depend on product type:

Grain Mill Products:
TSS 100 mg/L

Fats and Oils Products:
TSS 100 mg/L
BOD5 25 mg/L
COD 120 mg/L
Ammonia 34.8 mg/L
Total nitrogen None

All Other Food Sectors:
TSS 100 mg/L
BOD 25 mg/L
COD 120 mg/L
Ammonia 34.8 mg/L
Total nitrogen 10 mg/L
Phosphorus 1.0 mg/L

Note: Benchmarks for ammonia and nitrate were derived based on the Aquatic Life Standards for these parameters in Minnesota Rules.

[Read more about use of Aquatic Life Standards to derive stormwater benchmarks]
[Read more about how benchmarks are used under the proposed MPCA industrial permit]
[Read more about what a 100 mg/L benchmark for TSS relates to]

Looking for other sector information? Click here for information on proposed stormwater requirements for specific sector.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Proposed MPCA SWPPP Requirements for Electric Generating Facilities

On July 6, 2009, the Minnesota Pollution Control Agency released its proposed multisector industrial stormwater discharge general permit. This permit, once promulgated, will replace the existing industrial stormwater permit, which expired in October of 2002.

[Read a summary of the overall Minnesota permit, stormwater monitoring, and sector requirements]

Caltha LLP will be conducted seminars on the proposed sector requirements in July & August 2009. Caltha MPCA Industrial Stormwater Permit Requirements Seminars

The proposed permit details requirements for 29 different industrial sectors. The requirements described below are proposed for the Steam Electric Generating Facilities (Sector O). Sector O covers three primary types of facilities, 1) steam electric power generation using coal, natural gas, oil, nuclear energy, etc., to produce a steam source; 3) dual fuel co-generation facilities; and 3) alternative fuel generating facilities used to produce steam.

These requirements are in addition to permit requirements that apply to all sectors.

Good Housekeeping Practices:
The SWPPP must describe and implement procedures to reduce or control the tracking of ash and residue from ash loading areas. Clear the ash building floor and immediately adjacent roadways of spillage, debris, and any excess water before departure of each loaded vehicle.

Inspections
Inspections must include:
a) coal handling areas,
b) switchyards,
c) ash handling areas,
d) areas adjacent to disposal ponds and landfills.

Inspections must include all residue-hauling (i.e. ash) vehicles for proper covering over the load, adequate gate sealing, and overall integrity of the container body. Dischargers must repair, as soon as practicable, vehicles without load covering or adequate gate sealing, or with leaking containers or beds. Two of the monthly inspections must be conducted during runoff events and one of the inspections shall be performed during a snow melt runoff event.

Preventative Maintenance:
The SWPPP must describe and implement measures that prevent or minimize stormwater from contacting fugitive dust emissions from coal handling areas and to prevent or minimize contamination of stormwater runoff from delivery vehicles carrying significant materials arriving at the facility. The SWPP must have procedures ensuring overall integrity of the body or container and procedures to deal with leakage or spillage from vehicles or containers.

The SWPPP must also describe and implement measures that prevent or minimize contamination of surface runoff from oil-bearing equipment in switchyard areas and to retard flows and limit the spread of spills from oil-bearing equipment in switchyards, or collecting runoff in perimeter ditches from these areas.

Spills and Leaks:
The SWPPP must describe and implement measures to reduce the potential for an oil or chemical spill, or reference an SPCC plan, and to visually inspect the structural integrity of all above-ground tanks, pipelines, pumps, and related equipment, and conduct any necessary repairs immediately.

Management of Runoff:
The SWPPP must describe and implement measures that prevent or minimize contamination of surface runoff from areas adjacent to disposal ponds or landfills, and must include procedures to reduce ash residue that may be tracked on to access roads traveled by residue handling vehicles, and reduce ash residue on exit roads leading into and out of residue handling areas.

SWPPP Contents:
The SWPPP must identify:
1) scrap yards, and general refuse areas;
2) short- and long-term storage of construction materials, paint equipment, oils, fuels, used and unused solvents, cleaning materials, paint, water treatment chemicals, fertilizer, and pesticides);
3) landfills and construction sites; and
4) stockpile areas (e.g., coal or limestone piles).

Stormwater Monitoring Benchmarks:
All facilities are required to conduct visual and chemical (benchmark) monitoring. For benchmark monitoring, the benchmark concentrations or values depend on facility type:

Coal Fired and Oil Fired Steam Electric Generating Facilities:
TSS 100 mg/L
Iron 1.0 mg/L

Nuclear and Natural Gas Fired Co-Generation Facilities:
TSS 100 mg/L

[Read more about how benchmarks are used under the proposed MPCA industrial permit]
[Read more about what a 100 mg/L benchmark for TSS relates to]

Looking for other sector information? Click here for information on proposed stormwater requirements for specific sector.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website